ML20236X810
| ML20236X810 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/04/1998 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-277-98-04, 50-277-98-4, 50-278-98-04, 50-278-98-4, EA-98-247, NUDOCS 9808100273 | |
| Download: ML20236X810 (3) | |
See also: IR 05000277/1998004
Text
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August 4, 1998
EA 98-247
Mr. G. Rainey, President
PECO Nuclear
Nuclear Group Headquarters
Correspondence Control Duk
P. O. Box 195
Wayne, Pennsylvania 19087-0195
SUBJECT: PEACH BOTTOM INSPECTION REPORT NOS. 50-277/98-04 AND
50-278/98-04- REPLY
Dear Mr. Rainey:
This letter refers to your June 17,1998 correspondence, in response to our May 14,1998
integrated inspection report and notice of violation. This inspection focused on the
licensed operator requalification training (LORT) program (March 9,1998, through
March 13,1998) and maintenance rule baseline inspection open items, (March 30,1998,
through April 3,1998) at the Peach Bottom Atomic Power Station, Delta, Pennsylvania.
We have reviewed this matter in accordance with NRC Inspection Manual Procedure
92901," Plant Operations." We concur with your assessment of the root causes and
corrective actions as summarized below.
The first violation involved a failure to assure sufficient differences in the job performance
measure (JPM) portion of the operating test administered to different crews on different
weeks. The cause was a methodology that was not clearly defined and corrective action
was focused on a training procedure enhancement.
Also for this violation you indicated that "... Knowledge of a specific JPM set in the 5th
administration of the exam would have required the individual to interview 32 previous
trainees". Our review does not agree with this assessment and concluded that one
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individual could talk on the right occasion (however remote) to a second individual who
had knowledge of an examination previously administered in order for the first individual to
gain knowledge of a substantial portion of the examination being duplicated. Our inspector
identified a number of examples in which JPM sets were repeated in subsequent exam
weeks. Howevst, we acknowledge your assessment of no actual compromise for the
subject examination.
The second violation involved the failure of your operating test to evaluate SROs fulfilling
the role of the control room supervisor in their ability to execute the emergency plan. The
cause was an inadequate course plan and corrective actions were focused on testing the ,
SROs immediately after the inspection identified the problem and on revising the course
plan.
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9808100273 980804
PDR ADOCK 05000277 I
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Mr. G. Rainey 2
A third violation involved a failure to include the area radiation monitoring system within
scope of the maintenance rule (MR) program in accordance with 50.65(b). Two apparent
causes were identified: personnel erroneously predispositoned to the meaning of mitigation
and inadequate incorporation of operating experience into the MR program, in addition to
adding the subject equipment to the scope of the MR and other lessons learned, corrective
actions were focused on a re-review of abnormal and emergency procedures to assure
proper MR rule scoping.
Also, your letter adequately responded to our concern on the adequacy of shift manager
oversight of control room supervisors.
The effectiveness of your corrective actions will be reviewed in a subsequent inspection.
We appreciate your cooperation.
Sincerely,
ORIGINAL SIGNED BY:
Richard J. Conte, Chief
Operator Licensing and
Human Performance Branch
Division of Reactor Safety
Docket Nos. 50-277;50-278
cc w/cy of Licensee Letter:
G. Edwards, Chairman, Nuclear Review Board and Director, Licensing
J. Doering, Vice President, Peach Bottom Atomic Power Station
J. Hagan, Vice President, Nuclear Station Support
R. Boyce, Director, Nuclear Quality Assurance
A. F. Kirby, Ill, External Operations - Delmarva Power & Light Co.
M. Warner, Plant Manager, Peach Bottom Atomic Power Station
G. J. Lengyel, Manager, Experience Assessment
J. W. Durham, Sr., Senior Vice President and General Counsel
T. M. Messick, Manager, Joint Generation, Atlantic Electric
W. T. Henrick, Manager, External Aff airs, Public Service Electric & Gas
R. McLean, Power Plant Siting, Nuclear Evaluations
J. Vannoy, Acting Secretary of Harford County Council
R. Ochs, Maryland Safe Energy Coalition
J. H. Walter, Chief Engineer, Public Service Commission of Maryland
l Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance
Mr. & Mrs. Kip Adams
Commonwealth of Pennsylvania
State of Maryland
TMI Alert
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Distribution w/cv of Licensee Letter:
Region i Docket Room (with concurrences)
B. Fewell, ORA
D. Holody, ORA
R. Zimmerman, ADPR, NRR
F. Davis, OGC
A. Nicosia, OGC
J. Lieberman, OE
C. . Anderson, DRP
. D. Florek, DRP
B. Junod, DRP
J. Wiggins, DRS
L. Nicholson, DRS
R. Conte, DRS
J. Williams, DRS
J. Caruso, DRS
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
PUBLIC
DRS File
B. McCabe, OEDO
R. Capra, PDI-2, NRR
inspection Program Branch, NRR (IPAS)
M. Thadani, NRR
B. Buckley, 'NRR
M. Campion, ORA
DOCDESK
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DOCUMENT NAME: G:\0LHP\caruso\PB9'804. REP
To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No
copy
OFFICE Rl/DRS .
Rl/DRS Rl/DRP Rl/DRP NRR
nrl _ _ . , n/
NAME JCarusoJ//jf 7) JWilliams PV RContef 'f' CAnderson (/f e
DATE 08ff/9B VV*
08/4/98 08/t/98 / 084 /98 08/ /98
OFFICIAL RECORD COPY
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Pesch Bottom Atome Power Station
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J0ne 17,1998
Docket Nos. 50-277
50-278
License Nos. DPR-44
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DPR-56 {
l U. S. Nuclear Regulatory Commission
l Attn.: DocumentControlDesk
l Washington,DC 20555
l Subject: Peach Bottom Atomic Power Station Units 2 & 3
l Response to Notice of Violations (Combined Inspection Report No. 50- .
277/98-04 & 50-278/98-04)
l Gentlemen: l
In response to your letter dated May 14,1998 which transmitted the Notice of Violations
concerning the referenced inspection report, we submit the attached response. The
subject report focused on the licensed operator re-qualification training (LORT) program
and maintenance rule baseline inspection open items inspections that were conducted
from March 9 through April 3,1998.
If you hav any questions or desire additionalinformation,do not hesitate to contact us.
.V ,
John Doering, Jr.
t Vice President,
Peach Bottom Atomic Power Station
Attachments i
MT/mt
cc: N.J. Sproul, Public Service Electric & Gas
R. R. Janati, Commonwealth of Pennsylvania
H. J. Miller, US NRC, Administrator, Region I
A. C. McMurtray, US NRC, Senior Resident inspector
R. l. McLean, State of Maryland
A. F. Kirby Ill, DelMarVa Power i
CCN 98-14039
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bec: OEAP Coordinator 62A-1, Chesterbrook
Correspondence Control Program 618-3, Chesterbrook
NCB Secretary (11) 62A-1, Chesterbrook
G. R. Rainey 63C-3, Chesterbrook
J. Doering SMB4-9, Peach Bottom
J. B. Cotton 62C-3, Chesterbrook
T. J. Niessen 53A-1, Chesterbrook
E. J. Cullen S23-1, Main Office
T.A.Shea SMB4-6, Peach Bottom
G. D. Edwards 62A-1, Chesterbrook
J. G. Hufnagel 62A-1, Chesterbrook
C. J. McDermott S13-1, Main Office
M. E. Warner A4-1S, Peach Bottom
G. L. Johnston SMB3-5, Peach Bottom
R. L. Gambone A4-1S, Peach Bottom
R.A.Kankus 61C-1, Chesterbrook
G.J.Lengyel A4-4S. Peach Bottom
M.J. Taylor A4-SS, Peach Bottom
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RESPONSE TO NOTICE OF VIOLATION 98-04
RestatementofViolation
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Violation 1
10 CFR 50.54(i-1) requires that the facility licensee shall have in effect an operator re-
qualification program which must as a minimum, meet the requirements of 55.59(c).10 CFR
55.59(c) requires, in part, that in lieu of paragraph (c)(4) of this section, the Commission may
approve a program developed by using a systems approach to training (SAT).10 CFR 55.59
(c)(4) requires, in part, that the facility licensee re-qualification program shall include
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comprehensive written examinations and annual operating tests which determine areas in
! which retraining is needed to upgrade reactor operator and senior reacto'r operator knowledge.
Peach Bottom's SAT-based re-qualification program procedure POC-2.4, " Licensed Operator
Re-qualification Training", requires in part, that subsequent examinations shall be designed to
be greater than 40% different than previous examinations developed for the same annual
operating test.
Contrary to the above, from January 1998 to March 13,1998, the facility licensee administered
the annual operating test to operators in a manner such that examination test item sample
i selection was not sufficiently comprehensive. Specifically, there was a pattern of overlap in that ;
l every JPM set was used at least twice on two different crews on different examination weeks.
This resulted in 0% difference when comparing any two particular crews which got the 4
overlapping JPM sets.
This is a Severity Level IV violation (Supplement 1).
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Violation 2
10 CFR 55.59(a)(2)(ii) requires, in part, that the operating test will require the licensed senior
operator to demonstrate the ability to perform the actions necessary to accomplish a
l comprehensive sample of items specified in part 55.45(a)(2) through (13) inclusive to the extent
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applicable to the facility.10 CFR 55.45(a)(11) requires, in part, the licensed senior operator to
demonstrate the ability to execute the emergency plan.
Contrary to the above, operating tests administered from January to March 1997 and from
January through March 13,1998, did not require licensed senior reactor operators fulfilling the
i role of the Control Room Supervisor to demonstrate on a sampling basis their ability to execute
the emergency plan.
This is a Severity Level IV violation (Supplement 1). l
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Violation 3
10 CFR 50.65(b) established the scope of the monitoring progiam for selection of safety-related and non-
safety related structures, systems or components (SSCs) to be included within the maintenance rule program.
The monitoring program shall include, in part, non-safety related SSCs that are used in the plant emergency
operating procedures.
Contrary to the above, as of April 1,1998, the licensee failed to include the area radiation monitoring system
within the scope of the maintenance rule program. The area radiation monitoring system is a nonsafety-
related system used in the plant emergency operating procedures.
This is a Severity Level IV violation (Supplement 1).
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Backaround Inforrnation
Violation 1
The Peach Bottom Job Performance Measures (JPM) portion of the annual and biennial operating exam was
d: fined as those JPMs that were developed and administered during a given week. A subset of this exam
was reused to prepare an exam to be administered later in the exam cycle that was greater than 40 percent
different. The JPM exam should have been defined as those JPMs administered to an individual. Based
upon this when JPMs were reused to develop additional exams a zero percent difference between two
administered exams existed.
Violation 2
LORT exam development is performed using the skills, knowledge and on-the-job experience of the Nuclear
Licensed Operations training instructors and the NRC examiner standards as a guideline.10 CFR 55.45
provides a listing of the information that is to be included in the operating tests administered to holders of
reactor operator and senior operator licenses. This section requires the individual to demonstrate an
understanding of and the ability to perform the actions necessary to accomplish a representative sample from
among the list of 12 items, one of which deals with the emergency plan. LORT course plan POC-2.4 is the
guidance document for development and administration of the exams to the licensed operator. There is no
s:ction in this course plan that specifically states the information to be considered as part of the sample plan
that would include the evaluation items from 10 CFR 55.45. It is from this document that the required LORT
exams are generated. This led to the development of the exam which excluded the evaluation of the Control
Room Supervisors in their ability to properly implement the Emergency Plan in the operating portion of the
exam. Implementation of the emergency plan by the CRS did not have a rating that would require inclusion in
the Biennial Operating exam.
Violation 3
While closing open items generated during the Maintenance Rule Baseline inspection, the NRC identified that
Area Radiation Monitors (ARMS) used in Emergency Operating Procedures (EOPs) were not included in the
scope of the Maintenance Rule contrary to 10 CFR 50.65.10 CFR 50.65 requires that non-safety related
equipment that is used in EOPs be within the scope of the Maintenance Rule. Additional guidance in
interpreting this requirement is given in NUMARC 93-01. NUMARC 93-01 states that for non-safety related
vstems, Structures and Components (SSC) to be considered important, the SSC must add significant value
to (. e mitigation function of an EOP by providing the total or a significant fraction of the total functional ability
rega -i to mitigate core damage or radioactive release. PECON has defined significant mitigation as the
ability cr the SSC to successfully fulfill the necessary function during an event at the point in the EOP when it
is directed to be placed in service. The significance of the mitigation function should be based on the actions
required and the impact the particular SSC will have on the event. This PECON definition focuses on the
- capability of the device to directly mitigate the event. However, the NRC has interpreted this requirement to
l b3 the equipment's ability to perform a significant mitigation function by allowing performance of the EOP. In
! this particular situation, if ARMS were not available then the secondary containment radiation control leg of T-
103, " Secondary Containment Control" could not be completed.
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Reason (s) For The Violation
Violation 1
One apparent cause for this violation was identified in that, the methodology to meet the forty percenc l
difference of the Job Performance Measures exam was not clearly defined in the present Licensed
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Operator Requalification course plan. The lack of guidance resulted in, as seen by the inspector, a 100 j
percent duplication of a JPM eram in the 5'" administration of the exam. This duplication raised the issue
of potential compromise of the exam. The event investigation indicates that the exam was not {
compromised for the following reasons. j
o Individuals are briefed, prior to administration of the exam, that no aspects of the exam are to be
discussed with other trainees until the conclusion of the exam period.
o By the time a set of five JPMs were reused,32 operators had been tested with various combinations
of 53 JPMs. Until the first repetition of the five JPMs, each set of two operators received a new set
of JPMs. Knowledge of a specific JPM set in the 5'" administration of the exam would have required
the individual to interview 32 previous trainees.
e No anomalies in exam performance were observed during the 5'" administration of the exam or '
subsequent administration of the exam.
Violation 2
The event investigation identified that the Control Room Supervisors ability to properly implement the
Emergency Plan had not been captured in LORT Course Plan 2.4. The requirements of 10 CFR 55.45
were not captured in any documented formal process for the development of the Licensed Operator
exam. This omission prevented the identification of any potential weaknesses in the skills and knowledge
of the Control Room Supervisor SROs regarding the implementation of the Emergency Plan.
Violation 3
Two apparent causes were identified in the event investigation. One being personnel predispostioned to
the meaning of mitigator as PECO has used in MR determinations and the other the inadequate
incorporation of operating experience into the Maintenance Rule. In both accident and probabilistic safety
assessment analysis a mitigator or something that mitigates, had been defined as something that
performs an active function to reduce the effects of the event in progress. This is well beyond
something that simply performed a notification or indication function. When NUREG-1526 was issued
and discussed at an information conference, the example of how another plant interpreted the meaning of
NUREG 93-01 guidance was thought by PECON to be one of several ways to meet the requirement. Due
to this predisposition, the PECON defined way was thought to be an acceptable way to comply with the
requirements of the regulation. In addition, during the NRC baseline inspection, scoping of the
Maintenance Rule was found to be satisfactory and therefore did not trigger a re-examination of the
PECON interpretation of significant mitigator.
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( Corrective Steps That Will Be Taken To Avoid Further Violations !
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Violation 1 l
A well defined process will be developed to ensure compliance with the 40 percent JPM exam difference are
mit for annual and biennial exams. This process will be captured in the LORT course plan POC-2.4.
Violation 2
Immediate corrective actions were to examine a representative sample of Control Room Supervisor (CRS)
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SROs to determine their ability to implement the Emergency Plan. This was done satisfactorily by all 12 CRS
SROs sampled. This sample, in addition to the Shift Managers sampled, represents greater than 50 percent
of the population of all SROs. Licensed Operator Requalification Course Plan POC-2.4 will be revised to
include a process to ensure that the requirements of 10 CFR 55.45(a)(2)-(13) are satisfied. l
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Violation 3
Area radiation monitors were included in the Maintenance Rule scope for the plant and other lessons learned
thtt are documented in NUREG-1526 have been evaluated for incorporation under the Rule. All Off Normal
(ON), Operational Transient (OT), Special Event (SE), and Trip (T-200 and T-100 series) procedures were
also reviewed to identify SSCs that are used as significant mitigators in EOPs that may be covered by the l
Maintenance Rule.
Shift Manaaement Oversicht
in the Notice of Violation letter dated May 14,1998, you requested that we address the weakness of the Shift ;
Managers in their oversight of the Control Room Supervisor (CRS), and any corrective actions planned or I
trken. Expectations regarding Shift Manager oversight of Control Room Supervisors is clearly defined in the !
Operations Manual. Specifically, section 2.2.3. of OM-P-3.2, " Senior Licensed Operators", requires that the
shift manager continually evaluate Operations Shift Team personnel performance, alertness and attentiveness '
and provide instructions, guidance, or counsel as required. Contrary to the requirements of the Operations
Manual, Management's expectations were not carried out or reinforced by the Shift Managers. During
Licensed Operator Requalification training, instances where Control Room Supervisors performance does not
m:et expectations and the Shift Manager fails to address the performance are identified and discussed during
the post-training critique. In a similar manner, evaluation of Control Room Supervisor performance during the
operating portion of the biennial exam identified instances where three-part communication, Emergency .
Operating Procedure flow chart mark-up and crew briefings did not meet expectations. In some instances, the l
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Shift Manager did not address the Control Room Supervisor performance during the dynamic portion of the i
exam. The post-exam critique identified these performance issues and assessed their impact on exam grade.
It was determined that these incidents represented an area for improvement, since the Control Room
Supervisor performance and Shift Manager oversight did not meet expectations but that the overall evaluation
was satisfactory.
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The Senior Manager of Operations met with the Shift Managers to ensure a clear understanding of
[ expectations. The Senior Manager Operations also issued a letter to all licensed holders explaining recent
l performance issues, reinforcing expectations and immediate corrective actions. These areas for improvement
have been communicated with the individuals involved. These performance issues will continue to be ;
assessed and critiqued during 1998 LOR year program.
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Date When Full Compliance Will Be Achieved
Violation 1
The process for exam development to ensure required minimum overlap will be completed and . incorporated ,
into the LORT course plan POC-2.4 prior to the development of thc next Annual LOR Operating Exam in
J;nuary 1999. J
Violation 2
The examination of a representative sample of Control Room Supervisor SROs to determine their ability to
implement the Emergency Plan was completed by April 30,1998. Licensed Operator Requalification Course 1
Plan POC-2.4 revisions will be completed prior to the development of the next Annual LOR Operating Exam in j
J;nuary 1999. This revision will include a method to ensure the requirements of 10 CFR 55.45 are cap +.ared.
Violation 3
Area radiation monitors were incorporated into the scope of the Maintenance Rule on April 3,1998. A review
of SSCs identified in procedures that may need to be included under the Maintenance Rule was completed on
June 5,1998. Ten SSCs were identified as needing further review for possible inclusion. This review will be
completed by July 31,1998,
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